This post comes out from daily, personal experience in Shanghai.
A friend of mine mentioned to me that she had enjoyed an amazing lavender-drink in a cosy café in the former French concession, and that it tasted great.
Maybe she expected a nice reaction from me, but instead I could suggest to her to enjoy the lavender-drink as much as she could before…somebody would find out that lavender is a herb expressly forbidden to be used for food in China. In a notice issued in 2015, the Ministry of Health declared that “Due to the lack of relevant information such as edible parts of lavender, methods of eating, food history, population, and safety, the management methods cannot be determined. … To turn lavender …. into an ordinary food raw material, it should be in accordance with the procedures stipulated in the “Administrative Measures for the Inspection of the Safety of New Food Raw Materials”.”
Unless – of course – instead of real lavender, the café was using lavender oil (which is an allowed flavoring under Chinese regulations).
Similar situation for poppy seeds. Poppy seeds are an interesting case, as they appear on the list of food condiments GB 12729.1/2008. However, a notice issued by the Ministry of Health in 2013 clearly forbids poppy seeds from being used as food condiment.
Both poppy seeds and lavender are used in food industry outside of China.
In general, it is important to verify whether ingredients used in the recipe appear on any “black list” issued by Chinese relevant authorities (usually, Ministry of Health and now NHFPC).
It can happen that some herbal ingredients appear on the Chinese pharmacopoeia, in which case it becomes critical to understand whether these ingredients can be considered both traditional Chinese medicine ingredients and food ingredients.
To move from black-list to white list, usually it is necessary to carry out the novel food approval procedure.